March 2, 2020
Gentlemen:
I urge you not to adopt Rule #S7-24-15 because investment companies are already required to provide significant disclosure about the risks associated with investing in their funds.
I am 74 years old, and I have been using leveraged and inverse funds for the past 6 years. Granted, I am not your average investor because I am a CPA, have an MBA with a concentration in finance, worked as a staff account in the SEC's Chicago office for 10 years, and, prior to that, oversaw $2.3 billion in retirement assets for American National Can Company as their Director of Pensions and Investments.
One thing that the SEC could do to help protect investors, is to require investment companies to report the annualized, 3-year standard deviation for each of their funds. this is the standard quantitative measure of risk used nearly universally by investment professional. In requiring such disclosure, the SEC should also prescribe the formula for calculating the annualized standard deviation to avoid any innovative approaches that portfolio managers might be tempted to use.
Very truly yours,
Walter H Melcher